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Privacy Policy

The family of brands owned and operated by Ingenovis Health, Inc., including Trustaff, Fastaff, HealthCare Support, U.S. Nursing, VISTA Staffing, Springboard Health, VitalSolution, Corazon, and their subsidiaries and affiliates (collectively, the “Company” or “we” or “our”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy (“Policy”) and Notice at Collection.

This Policy describes the types of information we may collect from you or that you may provide when you visit the Company’s websites, including: ingenovishealth.com, trustaff.com, fastaff.com, healthcaresupport.com, usnursing.com, vistastaff.com, springboardhealthcare.com, vitalsolution.com and corazoninc.com (collectively, the “Websites”), or when you download and use one of our mobile applications (the Websites and mobile applications are, collectively, the “Online Services”). This Policy further describes our practices for collecting, using, maintaining, protecting, and disclosing that information in connection with our recruiting, staffing, employment, and consulting services which shall also be considered “Online Services” for purposes of this Policy. Employees, independent contractors, and job applicants should review any applicable separate privacy notices we provide to you, or make available to you. If there are any conflicts between this Policy and any separate privacy notice, the separate notice controls.

By accessing or using the Online Services or accepting employment or a contract or assignment through us, or remaining employed with us, you consent to the collection, use, and processing of your personal information by the Company in accordance with this Policy. If you do not agree to the terms of this Policy, please do not use the Online Services or apply for employment with the Company. Where required by applicable law, we rely on one or more of the following legal bases to process personal information: to enter into or perform a contract with you; to evaluate you for employment and/or to be placed on assignment with a client through our Company; to comply with legal and regulatory obligations; to operate, evaluate, and improve our business, recruiting and staffing activities; to communicate with you, with your consent where required by law; and to establish, exercise or defend legal claims.

We reserve the right to change or update this Policy at any time. If we change this Policy, we will advise you of material changes through postings on our Websites, and/or email to the primary email address you provide to us (if any) or push notifications through our mobile applications. Your continued access to or use of the Online Services and/or remaining employed after we provide notice will mean that you accept the changes. You are responsible for ensuring we have an up-to-date active and deliverable email address for you if you wish to receive change notices via email, and for periodically visiting our Websites and this Policy to check for any changes.

In accordance with all applicable laws, this Policy applies to all personal information we collect about you from any source, including:

  • Through the Online Services or any of your other interactions with the Company;

  • Via email, text, and other electronic messages between you and us, including through communications made through the Online Services;

  • Via telephone, mail, or other means of communicating with Customer Service or any other part of the Company;

  • Through mobile and desktop applications you download from the Websites or online application platforms (such as Google Play or the App Store), which provide dedicated non-browser-based interaction between you and the Online Services; and

  • When you interact with our advertising and applications on third-party websites and services, and if required by law, if those applications or advertising include links to this Policy.

Where required by law, this Policy does not apply to information collected by any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Online Services.

Please read this Policy carefully to understand our practices regarding your personal information. If you do not agree with our practices, it is your choice to not use our Online Services. By accessing or using the Online Services, you agree to this Policy. If you are located in California, you have opt-out rights further described below. And if you do submit your information to us and later change your mind, we try to honor your requests as further noted below.

Notice at Collection: Information We Collect and Share or Disclose, and Sources of the Information

We collect several types of personal information from and about users of our Online Services and at different points in the recruiting and staffing process. For example, limited information is collected at the time of submitting interest in a position, but if being considered, hired, and/or placed on assignment, additional information will be gathered and used to support our recruiting and staffing services. For purposes of this Policy, personal information is broadly defined to include, among other things, all information that can be directly or indirectly linked to an individual or household. In all cases, personal information does not include de-identified information, aggregate information that cannot be linked to a particular individual or household, or pseudonymized information.

Currently and for the 12-month period prior to the Updated Effective Date of this Policy (except as specified below), we have collected and shared the categories of information listed below. We retain such information for as long as necessary to fulfill the purposes described in this Privacy Policy, including for the duration of our relationship with you, and thereafter as necessary to comply with applicable legal, tax, accounting, or reporting requirements. We may also retain personal information as necessary to resolve disputes, enforce our agreements, and establish, exercise, or defend legal claims.

  • Contact information and identifiers

    , e.g., name, email address, postal address, phone number, digital signatures, online identifiers (such as username), passwords when you set up an account, or other contact details you may provide to us when you register or update an account, sign up for email communications, join our mailing list, or request materials from us. We collect this information when you provide it to us.

We may share this information with affiliates and subsidiaries wholly owned by us, our clients if you are assigned to work for them (the name of which will always be disclosed to you before you begin the assignment), and/or our service providers (a list you can ask for by contacting our Compliance team using the email address herein and that we will provide to you if required by law).

  • Internet and other online activity and device information

    , such as IP address; device ID; browser information and history; cookie information; operating systems; time stamps; the pages you request; the path you take on the Online Services; user settings; your use of our Online Services; search queries conducted on the Online Services; details of your use of the Online Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Online Services. We collect this information automatically when you use our Online Services.

We may share this information with affiliates and subsidiaries wholly owned by us, our clients if you are assigned to work for them (the name of which will always be disclosed to you before you begin the assignment), and/or our service providers (a list you can ask for by contacting our Compliance team using the email address herein and that we will provide to you if required by law).

  • Other voluntary information you provide to us

    , including if you use any of the services available through our Online Services, records and copies of your correspondence, resume, employment and education history, credentialing records, compensation requirements, and other relevant information, images and documentation you choose to send us or upload using our document repository. We collect this information when you provide it to us.

  • Image Collection and Use:

    When you use our Online Services, particularly our mobile application, users have the option to upload documents during the job application and placement process. This may include images, photographs, graphics, scans of certifications, identity proofs, and other related visual or document content. These documents aid in the streamlined and efficient processing of your job applications and placements.

  • Image Purpose:

    The primary purpose of collecting and processing these documents is to assess eligibility, qualifications, and fulfill other requirements related to the job application process. This ensures we provide potential employers and our clients with accurate and comprehensive information, streamlining the hiring process.

  • Image Consent:

    Transparency and trust are fundamental to our operations. Before accessing or uploading any documents or images, we always seek explicit consent from you, clearly explaining the necessity of the image information for the job application process. Denying such permissions may limit the functionality of the application process, but your right to privacy remains paramount, and we respect your decisions.

  • Image Sharing:

    These documents and images might be shared with potential employers, our clients, or our affiliates, subsidiaries, agents, or service providers when necessary to facilitate the intended purposes mentioned above. We explicitly disclose that image information is among the data being shared. All parties with access to this information adhere to stringent data protection measures to ensure your data remains protected.

  • Image Storage and Security:

    Protecting your personal and sensitive documents, including image information, is our top priority. We employ secure encryption and storage solutions and uphold the best industry practices to safeguard this data against unauthorized access, alterations, or deletions. We may share this information with affiliates, subsidiaries, agents, or service providers.

We may share this information with affiliates and subsidiaries wholly owned by us, our clients if you are assigned to work for them (the name of which will always be disclosed to you before you begin the assignment), and/or our service providers (a list you can ask for by contacting our Compliance team using the email address herein and that we will provide to you if required by law).

  • Personalization

    , such as your journey online and how you use our Online Services, whether and when you open our marketing emails and respond to our advertisements. We collect this information from you, from our Online Services technology’s interaction with your browser or devices and cookies tracking the pages you visit.

We may share this information with affiliates and subsidiaries wholly owned by us, our clients if you are assigned to work for them (the name of which will always be disclosed to you before you begin the assignment), and/or our service providers (a list you can ask for by contacting our Compliance team using the email address herein and that we will provide to you if required by law).

  • Preference information

    , your marketing preferences, your account settings (including any default preferences), any preferences you have indicated, the types of services/offers that interest you, the areas of our Site that you have visited or ways that you interact with our Site. We collect this information from you, from our website technology’s interaction with your browser/devices and cookies and other similar technologies tracking the pages you visit, and from the marketing messages you open and the links you follow.

We may share this information with affiliates and subsidiaries wholly owned by us, our clients if you are assigned to work for them (the name of which will always be disclosed to you before you begin the assignment), and/or our service providers (a list you can ask for by contacting our Compliance team using the email address herein and that we will provide to you if required by law).

  • Sensitive personal information,

    such as your driver's license, state identification card, work authorization documents, and passport numbers; your precise geolocation (if you permit us to obtain your precise geolocation); your demographic information including race, gender, age, disability, military status, ancestry, and national and ethnic origin; your biometric data (only if you are assigned to a client who uses it for timekeeping or security purposes); combination of email addresses; financial information like your bank account for purposes of compensation,

    payroll, benefits, tax, leave/accommodation, performance, disciplinary, timekeeping, training, background check, drug screen, credentialing/licensure, occupational health/safety, workers’ compensation, emergency contact, beneficiary/dependent, and client-assignment information

    ; and any other information when you provide it to us.

We may share this information only for permitted lawful purposes with affiliates and subsidiaries wholly owned by us, our clients if you are assigned to work for them (the name of which will always be disclosed to you before you begin the assignment), and/or our service providers (a list you can ask for by contacting our Compliance team using the email address herein and that we will provide to you if required by law). Such service providers include payroll processors, benefits administrators, background check vendors, credentialing vendors, occupational health/drug-screen providers, timekeeping systems, IT/security providers, cloud hosting, legal/advisory providers, and government agencies. It’s also possible we may disclose this data to third parties in the event we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets or if all or a substantial part of our assets are acquired by a third party, in which case the personal data that we hold about you may be one of the transferred assets. Where required by applicable law and not otherwise exempt, we will obtain additional necessary consents before processing your sensitive personal information.

  • Inferences

    drawn from information provided to us by you or third parties, to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. We collect this information from you and automatically when you use our Online Services.

We may share this information with affiliates and subsidiaries wholly owned by us, our clients if you are assigned to work for them (the name of which will always be disclosed to you before you begin the assignment), and/or our service providers (a list that you can ask for by contacting our Compliance team using the email address herein and that we will provide to you if required by law).

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Websites or transmitted to other users of the Websites or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Websites with whom you may choose to share your User Contributions. We cannot guarantee that third party vendors engaged by us who have access to User Contributions in connection with the services they perform will not provide access to User Contributions without authorization. We are not responsible for the actions or omissions of third-party vendors. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

All of the above information may be transferred to countries other than the country in which you are located, including to the United States, where data protection laws may differ. Where required by applicable law, we implement appropriate safeguards designed to ensure that such transfers comply with applicable data protection requirements, including through the use of standard contractual clauses or other approved transfer mechanisms.

Retention of Personal Information

We retain each category of personal information identified in the bullet points above for as long as reasonably necessary to fulfill the purposes described in this Policy or any applicable workforce privacy notice, including to provide recruiting, staffing, employment, assignment, credentialing, payroll, benefits, compliance, security, and business services; to maintain appropriate business and legal records; to comply with applicable legal, tax, accounting, healthcare, employment, and regulatory obligations; to resolve disputes; and to establish, exercise, or defend legal claims. The specific retention period for a category of personal information depends on the nature of the information, the context in which it was collected, our relationship with you, applicable client, facility, contractual, legal, and regulatory requirements, and whether the information is needed for security, audit, litigation, investigation, or compliance purposes. We may retain deidentified or aggregated information for longer periods where it cannot reasonably be used to identify you.

Please contact us as described in the “Contact Information” section below for more information on our data retention schedule.

Automated Processing and Use of Technology Generally

We may use automatic tools and data collection technologies, including artificial intelligence and machine learning technologies, to collect information about your online activities over time and across third-party websites or other online services and support our recruiting, matching, and communication processes. These tools are intended to assist our personnel and are not used as the sole basis for decisions that produce legal or similarly significant effects, unless otherwise disclosed. Where required by law, you may have the right to request information about our use of such technologies or to object to certain processing.

The technologies we use for automatic data collection may include:

  • Cookies (or browser cookies) A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser or available cookie management tools on our Websites. However, if you select this setting, you may be unable to access certain parts of our Websites. Unless you have adjusted your browser setting so that it will refuse cookies or directed our websites by rejecting cookies, our system will issue cookies when you direct your browser to our Websites.

  • Flash Cookies Certain features of our Online Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Online Services. Flash cookies are not managed by the same browser settings as are used for browser cookies.

  • Web Beacons Pages of the Websites and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We aim to include human oversight in decisions that could have a meaningful effect on you. In rare situations where a decision is made entirely through automated means (without human involvement), this will only occur where legally allowed and after you have been informed.

We are also committed to fair and unbiased treatment of all candidates when using HR technologies. To support this:

  • We routinely review system outputs to detect and address any potential bias.

  • We seek guidance from specialists to improve how we identify and reduce bias over time.

  • Our recruiters and matching systems are trained to work in tandem, ensuring both technology and human judgment are applied.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Online Services are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website, and that allows for tracking over time and across websites. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information – Our Business Purpose for Collecting the Information

Ingenovis Health, Inc. and its affiliates, and contracted partners engage with candidates via calls, AI-generated calls, text messages, and/or emails to share job opportunities. No mobile information obtained will be shared with third parties/affiliates for job marketing purposes, and we will not share text messaging opt-in data and consent with third parties for marketing purposes. Frequency varies for text messages. Message and data rates may apply. Carriers are not liable for delayed or undelivered messages. You can reply STOP to cancel.

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Online Services and their contents to you.

  • To provide you with information, products, or services that you request from us.

  • To fulfill any purpose for which you provide it.

  • To provide you with notices about your relationship with any of us.

  • To notify you about changes to our Online Services or any products or services we offer or provide though it.

  • To allow you to participate in interactive features on our Services.

  • To assist you in response to your requests to Customer Service.

  • To personalize and enhance your online experience, including as a way to recognize you and welcome you to the Online Services.

  • To provide you with customized content, targeted offers from other users, promotions and advertising on the Online Services, through other third-party sites or apps, via email, text messages, or push notifications that are offered by us or others that might be of interest to you.

  • To improve our Sites, products and services, customer service, and the customer experience.

  • To make sure our website and app technology works properly with your device and make sure you can see and use our intended website and apps on the device you are using

  • To protect the security or integrity of the Online Services and our business, such as by protecting against and preventing fraud, unauthorized transactions, and managing risk exposure, including by identifying potential hackers and other unauthorized users.

  • For analytical and demographic purposes.

  • In any other way we may describe when you provide the information.

  • For any other purpose with your consent.

Additional Disclosures of Your Personal Information

  • In addition to the disclosures described above, we may disclose personal information that we collect or that you provide to us as follows:

  • To comply with any court order, law, subpoenas, search warrants, judicial proceedings, legal process or law enforcement measures, including to respond to any government or regulatory request.

  • To enforce or apply our terms of use and other agreements.

  • To establish or exercise our legal rights, or to defend against legal claims.

  • To investigate, prevent, or take action regarding alleged or actual illegal activities, or as otherwise required by law.

  • To comply with applicable laws, including laws pertaining to taxes.

  • To administer a promotion, survey or other feature of our Services.

  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

  • We may also share information about you for any other purposes disclosed to you at the time we collect your information or with your consent.

  • To a prospective buyer or buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company is among the assets transferred, including in connection with any due diligence conducted in anticipation of such a transaction.

We may disclose anonymized and aggregated information about our users and information that does not identify any individual, without restriction. We do not sell personal information for monetary consideration.

SMS

Use of Automated Communications We, along with our affiliates and service providers, may contact you through phone calls (including automated or AI-assisted calls), text messages, or email to provide information about opportunities or services. Any personal information collected will be handled in accordance with our Privacy Policy.

Opt-In By subscribing to receive SMS notifications, you give us permission to send you text messages, which may include promotional content and alerts (such as job opportunities). These messages may be delivered using automated technology. By opting in, you confirm that you are at least 18 years old and that you are either the account holder for the mobile number provided or have authorization from the account holder to receive messages under these terms.

SMS Opt-Out You can unsubscribe from SMS communications at any time by replying “STOP” to any message. Once you opt out, you will no longer receive messages unless you choose to re-enroll.

Message Frequency The number of messages you receive may vary depending on your preferences and interactions. Message volume and length may differ by user.

Mobile Charges We do not charge fees for sending or receiving text messages; however, standard message and data rates from your mobile carrier may apply.

Help and Support For assistance, reply “HELP” to any SMS message you receive.

Security Measures

We have implemented measures designed to secure your personal information and information you upload to the Repository from accidental loss and from unauthorized access, use, alteration, and disclosure. No security measures are perfect or impenetrable. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to a part of one of our Websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we work hard to protect your personal information and information in the Repository from unauthorized access, alteration, disclosure, and loss, we cannot guarantee the security of your personal information transmitted to or stored through our Websites or that information will not be altered or lost. Any transmission, storage or loss of personal or other information is at your own risk. You should keep backup copies of all information stored on the Repository and check that materials on the Repository are accurate. We are not responsible for circumvention of any privacy settings or security measures contained on the Websites.

Your Rights With Respect to Personal Information We Collect

Depending on where you reside and the context in which we collect your personal information, you may have certain privacy rights under applicable state privacy laws. These rights generally apply to website users and consumers, and, in California, may also apply to employees, applicants, contractors, emergency contacts, and beneficiaries. Employment-context information may be excluded from certain non-California state privacy laws. Generally, we try to follow the following rights with respect to your Personal Information regardless of whether a state law requires us to do so or not:

  • The right to know what Personal Information we have collected, used, disclosed, and sold about you, including the categories of Personal Information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom we disclose Personal Information (and in some states, an actual list of specific third parties rather than just categories), and the specific pieces of Personal Information we have collected about you.

  • The right to obtain a copy of Personal Information we have obtained about you in a portable and, to the extent technically feasible, readily usable format.

  • The right to correct inaccurate personal information about you, taking into account the nature of the Personal Information and the purposes of the processing.

  • The right to request that we delete any Personal Information we have about you.

  • The right to opt-out of the selling your Personal Information, as applicable (which we do not do for monetary consideration).

  • The right to opt-out of the sharing of your Personal Information for purposes of targeted advertising (also called cross-context behavioral advertising and/or the profiling in furtherance of decisions that produce legal or similarly significant effects), which you can exercise on our website or by modifying your privacy preferences (e.g., Global Privacy Control), available through certain internet browsers and extensions, that signal your preference to opt out. Please note that clearing your cookies at any time will remove the signal of your selected privacy preferences.

  • The right to obtain information about automated processing, including to (1) know the reason behind the decision, (2) know what actions you might have taken to secure a different decision in the future, (3) review the personal data used, and (4) correct inaccurate personal data and have the decision reevaluated.

  • The right to opt-out of certain forms of automated decision-making (which is usually defined as the processing of personal information to analyze or predict personal aspects in furtherance of a significant decision).

  • The right to limit the use of your Sensitive Personal Information, which you can exercise through the contact form available on our website.

  • If we deny your request, the right to appeal our decision.

  • In addition, and as set forth below, California law requires us to identify, for the 12-month period prior to the date of this Privacy Policy, what information we may have “sold” or “shared” about you. For the 12-month period prior to the date of this Privacy Policy, we have not sold Personal Information for monetary consideration. It’s possible that third party cookies, pixels, tags, or similar technologies on our website may be considered a “sale.”

    In the preceding 12 months, our use of certain third-party cookies, pixels, tags, or similar technologies may have constituted a ‘sale’ or ‘sharing’ of online identifiers, internet or other electronic network activity information, and related inferences under California law.

  • You may opt out of these activities through our cookie preference tool, by using a recognized opt-out preference signal such as Global Privacy Control where required, or by submitting a privacy request.

  • For the 12-month period prior to the date of this Privacy Policy, we have only shared Personal Information as described above, including sharing information with our other entities of the Ingenovis group of companies for the purpose of efficient management of business, compliance with legal and regulatory requirements and to provide our services to you and to our clients. We do not use or disclose Sensitive Personal Information, as defined in applicable laws, for any purposes other than those permitted by applicable law.

Submitting Requests and Opt-Outs

You may submit your requests to opt out, correct, delete, and/or to know/obtain Personal Information we have collected about you by completing the form https://candidate.response.ingenovishealth.com/IGV-Request-To-Delete and indicating which brand your request pertains to. You can also call us by telephone at 720-248-5410. Employees, applicants, contractors, former employees, emergency contacts, and beneficiaries can use this link to access, delete, correct, opt-out, limit, and make other authorized-agent requests.

We will respond to your request in compliance with the requirements of your state’s applicable laws. Please note that we are only required to honor California requests to know twice in a 12-month period.

We also use Global Privacy Control (GPC) on our websites as an additional way to detect and honor your privacy selections. If you have GPC enabled, we honor your opt-out request and display visual confirmation in the URL bar. You can also always opt-out of the use of third-party cookies for personalized advertising by setting your cookie preferences on our website (it will be a banner and/or in a button on the bottom left of the screen) or on your browser.

This Privacy Policy describes how we may share your information for marketing purposes, as described above. You may have the right to request and obtain from us once per calendar year (and some more frequently) information about any of your Personal Information shared with third parties for their own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information. To request this information and for any other questions about our privacy practices and compliance with state law, please contact us at compliance@ingenovishealth.com.

Verification of Your Identity

When you exercise these rights and submit a request to us, we will verify your identity via means allowed by applicable law.

California Business Contact Information

If you are a California resident and we receive your Personal Information in the form of contact details from business events, for example as part of a business appointment (e.g., by exchanging business cards) or as part of any other form of collaboration, we may use your contact and business details to maintain our business contacts. For this purpose, we may transfer your contact details to our internal database. Pursuant to the CCPA, you have privacy rights with respect to your business contact Personal Information.

The processing activity may include the following categories of Personal Information:

  • Your contact information (e.g., name, title, form of address or salutation, address, gender, telephone numbers, email address); and

  • Details on your profession (e.g., job title, position, personnel number, place of work, branch office, department, qualifications).

  • This data processing is based on our legitimate business interests. We have a legitimate economic interest in maintaining contacts beyond the initial context and in using them to establish and develop a business relationship and to remain in contact with the parties concerned.

  • Such business contacts could also be easily processed in our email communications with you and then kept in typical business software, either centrally or on the electronic devices of our employees.

  • California law provides you with the following rights with respect to your personal information:

  • The right to know what personal information we have collected, used, or disclosed about you.

  • The right to request that we delete any personal information we have about you.

  • The right to correct inaccurate personal information about you.

We do not sell or share any of our business contacts’ Personal Information, as defined by the CCPA. California law requires us to identify, for the 12-month period prior to the date of this Privacy Policy, what information we may have “sold” or “shared” about you. For the 12-month period prior to the date of this Privacy Policy, we have not sold or shared any personal information about our business contacts.

Business contacts can use the same contact method described above under “Submitting Requests and Opt-Outs.”

Appeal

Residents of certain states may appeal a decision we have made regarding their requests by calling us at 720-248-5410.

Non-Discrimination

If you make a request under your state privacy laws, we will not discriminate against you in any way. For example, we will not deny you benefits or impose penalties on you or provide you with or suggest that you will receive a different level or quality of benefits or services.

Authorized Agents

You may permit an authorized agent to submit a request to know or to delete your Personal Information. If we receive a request on your behalf, we will ask that person to give us proof that you gave that person written permission to make a request for you. If that person does not provide us with written proof, we will deny their request so that we can protect your Personal Information.

Automated Decision-Making

We generally do not use automated decision-making technology, as that term is defined by State Privacy Laws. If we make use of automated decision-making technology, you will be informed through a separate privacy notice.

Minors Under Age 18 and Children Under Age 13

Our services are not directed to nor intended for minors under the age of eighteen (18). Minors under 18 years of age may not provide their personal information to or through our Online Services. We do not knowingly collect personal information from minors. If you are a minor, do not use or provide any information on any of the Online Services or on or through any of its features/register on any of the Online Services or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a minor or child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at Legal@ingenovishealth.com.

“Do not track” Signals

Some Internet browsers include the ability to transmit “Do Not Track” signals. We do not process or respond to “Do Not Track” signals.

Contact Information

To ask questions or comment about this Policy and our privacy practices, contact us at:

LEGAL & COMPLIANCE DEPARTMENT
Ingenovis Health
9997 Carver Road Suite 300
Blue Ash, OH 45242

legal@ingenovishealth.com / 720-248-5410
compliance@ingenovishealth.com

Updated Effective Date: July 2026